Dunning v. Meaney
In Dunning v. Meaney, 161 Vt. 287, 288, 640 A.2d 3, 4 (1993), the mother had physical custody, and the parents shared legal custody.
There, the Court held that the custodial mother's "move itself does not amount to a real, substantial or unanticipated change in circumstances justifying modification of the physical rights and responsibilities." Id. at 290, 640 A.2d at 5.